ML21350A194
| ML21350A194 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/2021 |
| From: | Leslie Fields Licensing Processes Branch |
| To: | |
| Fields L | |
| References | |
| Download: ML21350A194 (7) | |
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NRC Presentation Slides on NEI Remote Response White Paper, Draft C NRC Staff Comments & Discussion Items for December 15, 2021, Public Meeting Comments are used to indicate items that the NRC staff has identified as an item for NEI consideration. Other than NEI consideration, no further action is expected for these items. The comments below will be discussed during a review of Draft C of the NEI White Paper and are not intended to be a stand-alone document. Both Draft C of the NEI White Paper and these comments are needed to ensure proper context.
DISCUSSION ITEMS PAGE LOCATION Definition of "remote response" is embedded in a paragraph. Page 4, Background Would licensees that have approved ERO response times that are greater than that Page 4, Background, recommended in NUREG-0654 propose shorter ERO augmentation times based on First and Fourth "quicker response times?" Bullets Will the emergency plans and related implementation procedures be changed to reflect Page 4, Background, the larger ERO response? Fourth Bullet How will it be shown that a remote responder can adequately fulfill all applicable ERO Page 4, Background, functions? Last Sentence Will this white paper provide a method to demonstrate the capability for remote responders to fulfill all applicable ERO functions?
The general approach bullets do not appear to be consistent. The first seems to relate to Page 5, General site-specific emergency plans and the second could imply that if a licensee provides the Approach Bullets capability indicated in NUREG-0654, that proposed changes will not be a reduction in effectiveness. For each position recommended for remote response:
Do we know what responsibilities are performed by those ERO responders?
Are ERO responsibilities specifically identified with sufficient granularity to determine what functions are performed by ERO responders?
Typical emergency plans are high level documents that would have an engineer respond to provide engineering coverage related to a specific discipline. That statement does not really describe what an engineer must do to provide that coverage. Without that description, you cannot adequately justify moving that person to a remote location and simply state, since the engineer would be available by phone, the engineering coverage ERO function is met.
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NRC Presentation Slides on NEI Remote Response White Paper, Draft C NRC Staff Comments & Discussion Items for December 15, 2021, Public Meeting Comments are used to indicate items that the NRC staff has identified as an item for NEI consideration. Other than NEI consideration, no further action is expected for these items. The comments below will be discussed during a review of Draft C of the NEI White Paper and are not intended to be a stand-alone document. Both Draft C of the NEI White Paper and these comments are needed to ensure proper context.
DISCUSSION ITEMS PAGE LOCATION Considering that remote response will not provide the same communications options and Page 5, General capabilities of in-center response, it is not clear to the NRC staff how, [t]here will be no Approach Bullets reduction in the effectiveness of the ERO to respond to an emergency.
The NRC staff agrees with the ERO or ERF command and control statement in the first Page 6, paragraph. However, is this command and control for overall ERO command and control Recommended or the control of each ERF facility? These could be two different answers reflecting Positions, First different capabilities. Paragraph There are several recommended positions for a remote response that appear to be either Page 6, leadership or liaison positions. Both the regional EP inspectors and HQ had comments on Recommended these positions. Positions Page 6, Recommended Positions, Last Paragraph 2
NRC Presentation Slides on NEI Remote Response White Paper, Draft C NRC Staff Comments & Discussion Items for December 15, 2021, Public Meeting Comments are used to indicate items that the NRC staff has identified as an item for NEI consideration. Other than NEI consideration, no further action is expected for these items. The comments below will be discussed during a review of Draft C of the NEI White Paper and are not intended to be a stand-alone document. Both Draft C of the NEI White Paper and these comments are needed to ensure proper context.
DISCUSSION ITEMS PAGE LOCATION What does a Site Radiation Protection Coordinator actually do? Page 6, Positions 1 Is this different from a Radiation Protection Manager? and 2 Are both required?
Note: licensees typically make arguments for ERO staffing changes based on the generic descriptions in guidance and not based on their current emergency plan. If both of these positions are currently identified in a site-specific emergency plan, then a licensee must consider the potential impact of changes of either or both positions if remote response is being considered.
How is the Dose Assessment function at a NPP performed? Page 6, Position 3 The RP supervisor typically directly works with Dose Assessment Staff and then reports to the ED. This proposed list of ERO functions implies that they are individual pieces and not parts of an integrated team.
How will you ensure that the team still functions properly?
Do we have an analysis that shows how/what the ERO actually that the dose assessment, as proposed, would be effective?
What does the engineering support staff do and when do they need to do it? Page 6, Position 4 Are there any areas that are already successfully performed by phone (aka remotely) during normal operations and outages?
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NRC Presentation Slides on NEI Remote Response White Paper, Draft C NRC Staff Comments & Discussion Items for December 15, 2021, Public Meeting Comments are used to indicate items that the NRC staff has identified as an item for NEI consideration. Other than NEI consideration, no further action is expected for these items. The comments below will be discussed during a review of Draft C of the NEI White Paper and are not intended to be a stand-alone document. Both Draft C of the NEI White Paper and these comments are needed to ensure proper context.
DISCUSSION ITEMS PAGE LOCATION When are Security Liaison capabilities required? Page 6, Position 5 What does this individual actually do?
Are these capabilities redundant to position(s) identified in site-specific security plans?
Does the Security Liaison position require access to safeguards information and encrypted communications?
If so, how will access to safeguards information and encrypted communications be provided remotely?
Since several sites are already using a remote IT support group and others do not have Page 6, Position 6 critical digital assets identified per 10 CFR 73.54, either elimination of this capability or remote capability for this function already has precedent.
There were several regional EP inspector comments regarding remote IT Lead responders. The comments mostly questioned to ability to repair equipment remotely or how remote IT support would be effective if communications were lost.
NUREG-0654 already has a note that JIC/JIS staff to address media inquiries does not Page 6, Position 7 need to be performed at the TSC/OSC but needs to be established at 60 minutes, with additional JIC/JIS staff responding to the EOF within 60 minutes of a SAE.
Will an individual be available in the EOF to support the ED?
If not, why is it acceptable to not provide at least one individual in the EOF to provide media information support?
Need a clear definition of "reasonably similar." Page 6, Remote Additionally, the inclusion of "or between ERFs does not appear appropriate as a Collaboration standard for acceptable communication because ERFs are already "remote" from one Platform, First another and these communications are not typically face-to-face. Paragraph 4
NRC Presentation Slides on NEI Remote Response White Paper, Draft C NRC Staff Comments & Discussion Items for December 15, 2021, Public Meeting Comments are used to indicate items that the NRC staff has identified as an item for NEI consideration. Other than NEI consideration, no further action is expected for these items. The comments below will be discussed during a review of Draft C of the NEI White Paper and are not intended to be a stand-alone document. Both Draft C of the NEI White Paper and these comments are needed to ensure proper context.
DISCUSSION ITEMS PAGE LOCATION Need some sort of guide rails for remote collaboration platform analysis. As written, a Page 6, Remote licensee could state that we did an analysis, and it looks good to us. We asked each of Collaboration individuals and they all said that an operating phone is all that is needed. Platform, Second Paragraph How is the site-specific collaboration platform capability that supports remote ERO Page 7, Remote augmentation tested/evaluated? Collaboration Platform, First Paragraph after Bullets By their nature, suggestions are not required. May be cleaner to use one designation Page 7, Remote such as, "sites should consider," which would also be appropriate for non-required Collaboration suggestions. Platform, Third Paragraph after Bullets I would keep it simple and just ensure that resources identified in the emergency plan can Page 7, Remote be engaged as needed. The focus should be on those organizations that are included in Collaboration site-specific emergency plans. Platform, Fourth Paragraph after Bullets A separate "requirement" to perform software updates appears to be embedded in this Page 8, Specialized "example." Applications Last Paragraph Care must be exercised with the use of examples because they wind up overwriting the Page 8, Specialized actual guidance. Applications Last Paragraph 5
NRC Presentation Slides on NEI Remote Response White Paper, Draft C NRC Staff Comments & Discussion Items for December 15, 2021, Public Meeting Comments are used to indicate items that the NRC staff has identified as an item for NEI consideration. Other than NEI consideration, no further action is expected for these items. The comments below will be discussed during a review of Draft C of the NEI White Paper and are not intended to be a stand-alone document. Both Draft C of the NEI White Paper and these comments are needed to ensure proper context.
DISCUSSION ITEMS PAGE LOCATION There appears to be overlap with Response Time and Facility Activation comments and Page 8, Response comments for Call-out and Response sections. It seems that it would be more Time and Facility appropriate to place related comments in the Call-out and Response section. Activation.
Although the white paper does recommend that sites should implement reasonable Page 9, Call-out and control to ensure the availability of remote responders and implement compensatory Response measures in the event of a loss of capability to respond, no additional guidance other than these high-level statements were provided. Similar comments were made by both the Regional EP NRC inspectors and NRC HQ.
The last two sentences of the first paragraph seem focused and appropriate. All other Page 9, Call-out and information in this section, including the flowchart, lacks focus and/or appears Response First unnecessary. Paragraph The flowchart describes two steps that must be taken if communications are lost with a Page 10, Flowchart remote responder. The first step is for the remote responder who lost communications to communicate with the site ERO. The second step is to take a compensatory action. It does not appear that a flowchart is necessary.
If a flowchart is deemed necessary, it should be given a cold read by someone not involved in the development of the flowchart.
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NRC Presentation Slides on NEI Remote Response White Paper, Draft C NRC Staff Comments & Discussion Items for December 15, 2021, Public Meeting Comments are used to indicate items that the NRC staff has identified as an item for NEI consideration. Other than NEI consideration, no further action is expected for these items. The comments below will be discussed during a review of Draft C of the NEI White Paper and are not intended to be a stand-alone document. Both Draft C of the NEI White Paper and these comments are needed to ensure proper context.
DISCUSSION ITEMS PAGE LOCATION It is not apparent that all/most licensees have developed a task analysis that identified the Page 11, Training site-specific knowledges, skills, and abilities to implement their emergency plans. As and Qualification such, it may be difficult to identify changes to the existing emergency plan task analysis as a result of remote response for certain ERO augmenting responders. If the intent of the Training and Qualification section is to determine the training needs for remote response, this section should provide a high-level outline that supports identifying training needs.
This section should also provide guidance on training evaluation and documentation.
The Testing and Maintenance section seems similar/redundant to the Page 11, Testing and Equipment/Hardware section. Maintenance Recommend that NEI focus efforts on considering overall ERO staffing based on current emergency response capabilities. This would include FLEX, 10 CFR 50.155, and other relevant changes since Table B-1 of NUREG-0654, Revision 2, was published for comment.
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